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546 KB
Extraction Summary
3
People
3
Organizations
2
Locations
5
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing / defense motion (page 30 of a larger brief)
File Size:
546 KB
Summary
This is page 30 of a defense filing (likely a bail application) dated December 14, 2020, in the case against Ghislaine Maxwell. The defense argues that despite the government's initial claims of 'strong' evidence backed by flight logs and diaries, the 1.2 million pages of discovery produced so far contain no meaningful corroboration of the charges. The defense emphasizes that the produced documents largely date from the 2000s and 2010s, rather than the 1994-1997 period charged in the indictment.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the allegations; defense argues lack of corroborating evidence against her.
|
| Jeffrey Epstein | Deceased / Co-conspirator |
Mentioned in footnote regarding seized devices from his residences and in Daily Mail citation.
|
| The Government | Prosecution |
Accused by defense of misrepresenting the strength of documentary evidence.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Daily Mail |
Cited in a footnote regarding French prosecutors.
|
|
| French prosecutors |
Mentioned in a news citation as probing Epstein and Maxwell.
|
|
| The Court |
Accepted government proffers during the initial bail hearing.
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Timeline (5 events)
2019
Searches of Epstein's residences and seizure of electronic devices.
Epstein's residences
Law Enforcement
Jeffrey Epstein
Locations (2)
| Location | Context |
|---|---|
|
Mentioned in the Daily Mail headline regarding French prosecutors.
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|
|
Locations where electronic devices were seized in 2019.
|
Relationships (1)
Daily Mail headline mentions probing Maxwell to see if she was involved in his offending; discovery documents seized from his residences are being used in her case.
Key Quotes (3)
"The Discovery Contains No Meaningful Documentary Corroboration of the Government's Allegations Against Ms. Maxwell"Source
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Quote #1
"The vast majority of the discovery that the defense has reviewed relates to the time period in the 2000s and the 2010s, well after the conspiracy charged in the indictment (1994-1997)."Source
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Quote #2
"The discovery contains no meaningful documentary corroboration of the allegations whatsoever, much less 'significant' corroboration that the Court was led to believe existed."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,355 characters)
Case 20-5803 Document 39-2 01/07/2021 3067853 Page 36 of 45
Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 36 of 45
Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 36 of 45
E. The Discovery Contains No Meaningful Documentary Corroboration of the Government's Allegations Against Ms. Maxwell
At the initial bail hearing, the government represented to the Court that "the evidence in this case is strong" and that the allegations of the alleged victims were "backed up [by] contemporaneous documents . . . [including] flight records, diary entries, business records, and other evidence." (Dkt. 4 at 5.) The Court credited those representations and accepted the government's proffer that the witness testimony would be "corroborated by significant contemporaneous documentary evidence." (Tr. 82) (emphasis added). The defense, of course, could not rebut the government's representations at the hearing because the government had not yet produced discovery.
Since then, the government has produced, and the defense has reviewed, hundreds of thousands of pages of discovery, including the entire initial tranche of discovery that the government represented was the core of its case against Ms. Maxwell.⁹ The discovery contains no meaningful documentary corroboration of the allegations whatsoever, much less "significant" corroboration that the Court was led to believe existed. The vast majority of the discovery that the defense has reviewed relates to the time period in the 2000s and the 2010s, well after the conspiracy charged in the indictment (1994-1997). These documents include [REDACTED]
[REDACTED]
[REDACTED]
In fact, only
[REDACTED]
[REDACTED]
In fact, only
Daily Mail, "French prosecutors probing Jeffrey Epstein over rape and abuse of children in Paris widen probe to include Ghislaine Maxwell to see if British socialite was involved in his offending," (Oct. 25, 2020), https://www.dailymail.co.uk/news/article-8878825/French-prosecutors-probing-Jeffrey-Epstein-widen-probe-include-Ghislaine-Maxwell.html.
⁹ The defense has not yet completed its review of the over 1.2 million documents produced on November 9, 2020 and November 18, 2020. This production includes documents and images seized from electronic devices found at Epstein's residences in searches of his residences in 2019. Our initial review, however, shows that the documents are from the 2000s and 2010s, well after the charged conspiracy.
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DOJ-OGR-00020050
DOJ-OGR-00020050
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